Conflict of Interest Disclosure

General nature and sources of conflicts of interest

OSL Pay has identified two categories of potential conflicts of interest:

• Conflicts of interest potentially detrimental to clients of OSL Pay; and
• Conflicts of interest potentially detrimental to OSL Pay.

Conflicts of interest that are potentially detrimental to clients may arise when OSL Pay or OSL Pay shareholders or members, any person directly or indirectly linked to OSL Pay or OSL Pay's shareholders or members by control, OSL Pay's board members or OSL Pay's employees (the Connected Persons) are in any of the following situations:

• OSL Pay or the Connected Person is likely to make a financial gain, avoid a financial loss, or receive another kind of benefit, at the expense of the client;
• OSL Pay or the Connected Person has an interest in the outcome of a crypto-asset service provided to a client of OSL Pay or of a transaction carried out on behalf of that client, which is distinct from that client's interest in that outcome;
• OSL Pay or the Connected Person has a financial or other incentive to favour the interest of one or more clients of OSL Pay over the interest of another client of OSL Pay;
• OSL Pay or the Connected Person carries on the same business as the client of OSL Pay; or
• OSL Pay or the Connected Person receives or will receive from a person other than the client of OSL Pay an inducement in relation to a service provided to that client, in the form of monetary or non-monetary benefits or services.

Conflicts of interest that are potentially detrimental to OSL Pay may arise when a Connected Person:

• has an economic interest in a person, body or entity with interests conflicting with those of OSL Pay;
• has a personal relationship with a person, body or entity with interests conflicting with those of OSL Pay;
• has or has had a professional relationship with a person, body or entity with interests conflicting with those of OSL Pay;
• has a political relationship with a person, body or entity with interests conflicting with those of OSL Pay; or
• carries out conflicting tasks, is entrusted with conflicting responsibilities or is hierarchically supervised by someone who is in charge of conflicting functions or tasks.

Steps that OSL Pay has taken to mitigate these (potential) conflicts of interest

OSL Pay has implemented various measures to prevent the conflicts of interest set out above from arising:

• Through training, OSL Pay continuously ensures that Connected Persons are aware of the risks of conflicts of interest and the measures taken by OSL Pay to prevent them from arising.
• OSL Pay has implemented various strict policies and procedures that aim to prevent conflicts of interests from arising. These policies and procedures govern the following subjects:
  • Remuneration
  • Personal transactions
  • Acceptance of gifts
  • Promotion campaigns
  • Commissions
  • Ancillary activities
• Additionally, OSL Pay has implemented various measures in its internal governance to prevent conflicts of interest from arising within its organization and within the OSL group.

Evaluation and updates

OSL Pay maintains up-to-date records of all situations giving rise to actual and potential conflicts of interests and of the measures taken to mitigate such conflicts. This disclosure is regularly updated on the basis of those records, and evaluated annually for its accuracy, effectiveness and compliance with applicable regulations, addressing any deficiencies in that respect.